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Jay Sudha

MSME Amendment Bill 2026: Proposed Changes to the 45-Day Payment Rule and Delayed-Payment Recovery

The verified status of the MSME Amendment Bill 2026, the existing 45-day payment rule, delayed-payment interest, the ODR/MSEFC claim process, and Section 43B(h).

By Jay Sudha, Finance Educator··Updated July 19, 2026·31 min read
MSME Amendment Bill 2026: Proposed Changes to the 45-Day Payment Rule and Delayed-Payment Recovery
The 15/45-Day Payment Timeline
Day 0
Delivery
Goods delivered or services rendered. This is the anchor date the Act counts from.
Day 15
Objection window closes
No written objection by now means acceptance is deemed — silence does not stop the clock.
Day 45 (max)
Appointed day
The legal payment deadline — 45 days if agreed in writing, 15 by default. Nothing can push it later.
Day 46+
Interest starts
Compound interest, monthly rests, at 3× the RBI bank rate — automatically, by law.
45 days is the ceiling on what can be agreed in writing, not an entitlement every invoice gets automatically.
Delayed-Payment Recovery Roadmap
1
Verify & calculate
Confirm Udyam status, then work out the appointed day and the interest accrued.
2
Reminder, then demand
A factual reminder first; a written demand citing the MSMED Act if it is ignored.
3
Reconcile & document
Share an itemised statement; preserve every acceptance and payment communication.
4
File on the ODR portal
New complaints go to odr.msme.gov.in today, not the legacy Samadhaan portal.
5
MSEFC conciliation
The state council attempts a settlement — most resolved cases end here.
6
Arbitration & enforcement
If conciliation fails, arbitration follows, ending in an enforceable award.

Existing law today: a registered micro or small enterprise must be paid within 45 days of acceptance (if a period is agreed in writing) or 15 days (if nothing is agreed) — and late payment carries compound interest at three times the RBI bank rate. What's new: the Micro, Small and Medium Enterprises Development (Amendment) Bill, 2026 is listed for introduction in Parliament's Monsoon Session, aimed mainly at the dispute-resolution machinery (MSEFC composition, states' powers, arbitral-award enforcement) — not, on current reporting, the 45-day figure itself. If your invoice has already crossed the deadline: confirm your Udyam status, calculate the interest you are owed, and file on the MSME ODR portal (odr.msme.gov.in), not the older Samadhaan portal. Nothing below changes until Parliament actually passes something and it commences — this page tells you what is real today and what is still just a proposal.

Live legislative status — as of 19 July 2026, 6:00 PM IST

Bill name Micro, Small and Medium Enterprises Development (Amendment) Bill, 2026
Current stage Listed for introduction — named in the Lok Sabha's daily bulletin among five new Bills for the Monsoon Session; the Union Cabinet has separately approved the proposal to amend the Act
Introduced in Parliament? Not yet, as of this writing. Introduction happens during a live sitting, and the Monsoon Session is scheduled to begin around 20 July 2026
House of introduction Not yet confirmed. Government-agenda reporting is mixed — some coverage lists it under the Lok Sabha's business, other coverage lists it among Rajya Sabha's agenda. Check the daily bulletin of whichever House sits first once the session opens
Bill number Not yet publicly assigned/available
Official Bill text public? No. No Bill PDF, Statement of Objects and Reasons, or PRS Legislative Research summary was available at the time of this verification
Legally effective now? No. The MSMED Act, 2006 is unchanged. Every rule described in this article as "existing law" is in force today; everything described as "proposed" or "reported" is not
What is reported (not confirmed) about its content Strengthening the delayed-payment dispute mechanism, enforcement of arbitral awards for MSEs, and enabling states to decide the composition of their Micro and Small Enterprise Facilitation Councils, under a broader "ease of doing business / trust-based regulation" framing
Last verified 19 July 2026, via the Lok Sabha bulletin (as reported by multiple outlets), a Cabinet-approval press note from the Press Information Bureau, and the Ministry of MSME's public communications
Next expected step Formal introduction in Parliament during the Monsoon Session (20 July – mid-August 2026, per the government's tentative calendar), after which the Bill's actual text becomes public

A note on how this was verified: this page relies on the Lok Sabha's daily business bulletin (as syndicated by several independent news desks), a Press Information Bureau release confirming Cabinet approval of the proposal, and the Ministry of MSME's own portals. Attempts to pull the raw Lok Sabha bulletin PDF and India Code's Act text directly during this research were blocked by the source sites' bot protection, so some specifics (like the exact Bill number and confirmed House of introduction) rely on cross-checked secondary reporting rather than a primary document in hand — check the live Lok Sabha or PIB bulletin yourself for the final word once the session opens.

What changed today — the news-update block

  • Latest development: The Bill is listed among five new Bills for the Monsoon Session; the Union Cabinet has approved the proposal to amend the MSMED Act.
  • Exact date: Cabinet approval and the Lok Sabha's listing were both reported in the week of 14–19 July 2026, ahead of the Monsoon Session's start.
  • Source: Press Information Bureau (Cabinet approval release) and multiple outlets citing the Lok Sabha's daily bulletin.
  • Practical consequence today: None yet — no provision of the MSMED Act has changed. Suppliers and buyers should keep operating under the existing 45/15-day rule and existing interest formula.
  • What has not changed yet: The 45-day cap, the 15-day default, the 3× bank rate interest formula, Section 43B(h), and the Udyam eligibility rules are all unchanged. Nothing about "medium enterprises," retrospective effect, or a new interest formula has been confirmed anywhere.
  • Next expected update to this page: Once the Bill is formally introduced and its text is public, this block and the comparison table further down will be rewritten with the actual clauses, sections, and a revised headline (see the editorial note at the very end of this article for exactly what changes at each stage).

The existing MSME payment rule, in one table

This is the law as it stands today, under Sections 15 and 16 of the MSMED Act, 2006 — unaffected by anything currently proposed.

Situation Applicable deadline Legal basis Consequence of delay
No written payment agreement 15 days from acceptance/deemed acceptance Section 2(b) "appointed day" definition Compound interest, monthly rests, at 3× RBI bank rate from day 16
Written agreement, period ≤ 45 days The agreed period, as written Section 15 Same statutory interest from the day after the agreed period ends
Written agreement stating exactly 45 days 45 days from acceptance Section 15 Same statutory interest from day 46
Written agreement attempting more than 45 days (e.g. "60 days," "90 days") Capped at 45 days — the longer figure has no legal effect on the supplier's rights Section 15 (period "shall not... exceed forty-five days") Interest still runs from day 46, regardless of the PO wording
Buyer raises a written objection to goods/services within 15 days of delivery Clock restarts when the objection is resolved by the supplier Section 2(b), "day of acceptance" explanation Deadline is measured from resolution, not original delivery
No written objection raised within 15 days of delivery Deemed accepted on the delivery date itself Section 2(b), "day of deemed acceptance" Deadline measured from the actual delivery date
Payment made after the appointed day Section 16 Compound interest, monthly rests, 3× RBI bank rate, from the day after the appointed day to the date of actual payment

The 15-day vs 45-day confusion, cleared up

Two different, correct numbers get quoted for the same law, and most confusion comes from not knowing which one applies to a given invoice.

15 days is the default. If a buyer and a registered micro or small enterprise never put a payment period in writing — no clause in the purchase order, no agreed term in the contract — the law fills the gap with 15 days from acceptance. This is the fallback, not the norm; most commercial relationships do specify a term.

45 days is the ceiling on what can be agreed. If the parties do put a period in writing, they are free to agree to anything up to 45 days — 15, 21, 30, or 45 — but they cannot validly agree to more. A purchase order that says "60 days net" or "our standard is 90 days" is asking for something the Act does not permit; as far as the supplier's statutory rights go, the clock still runs out at day 45.

Acceptance, not the invoice date, usually starts the clock. The invoice date is a paperwork event; the day of acceptance is what the Act actually anchors to — the day of actual delivery of goods or completion of services. If the buyer raises a written, timely objection (within 15 days of delivery) about a genuine defect or shortfall, the clock resets to run from when that objection is resolved. If no such objection is raised in that window, acceptance is deemed to have happened on delivery day, full stop — silence does not stall the clock, it satisfies it.

A simple timeline example. A packaging supplier delivers cartons to a manufacturer on 1 June. The PO says "45 days." The manufacturer says nothing about any defect. Because no written objection arrived within 15 days (by 16 June), the goods are deemed accepted on 1 June — the actual delivery date. Counting 45 days from 1 June puts the appointed day at 16 July. If payment lands on 1 September, that is 47 days late, and interest runs from 17 July to 1 September, not from the invoice date or from 16 June.

Where this gets genuinely harder is a live, documented quality dispute — if the buyer did object in writing within 15 days, the "day of acceptance" shifts to whenever that objection was resolved, which can be weeks or months later depending on how the dispute played out. In that situation, the answer to "when was my 45 days" depends on the facts and the paper trail, not a clean formula — get it checked before assuming a date.

Who is protected — and who is not

Micro and small enterprises (as classified under the current Udyam criteria) are the enterprises the 45/15-day rule and statutory interest actually protect, as suppliers. Medium enterprises are not covered by Sections 15–16, even though "MSME" as a term includes them for registration, lending, and other purposes — a genuinely common point of confusion.

Manufacturing and service businesses are squarely within the Act's definition of "enterprise." Traders (wholesale and retail) sit in a specifically carved-out grey zone: government office memoranda from 2021 extended Udyam eligibility to traders for priority-sector lending purposes only, while explicitly excluding them from the delayed-payment benefits under the Act. Many traders register on Udyam anyway for the lending advantage; they should not assume the 45-day interest right travels with that registration.

Entity type does not matter — proprietorships, partnerships, LLPs, and companies are all eligible as suppliers, as are individual freelancers operating a genuine registered enterprise, provided the underlying activity qualifies and the enterprise is validly Udyam-registered.

Registration timing matters. The protection is generally understood to attach to a supplier that was validly registered as micro or small at the relevant time of supply — an invoice raised before registration existed sits in genuinely uncertain territory, and a business that later reclassifies (say, from micro to small as turnover grows) should expect its current classification, not a historical one, to govern new invoices going forward.

Where a court or MSEFC has taken a different view on any of these boundary questions than the general position described here, the answer may depend on the facts, registration timing, contract terms, and applicable judicial interpretation — this is not a settled area free of dispute, and a materially disputed classification is worth a professional opinion before you rely on it for a large claim.

The interest that makes buyers pay attention

Section 16 gives the 45/15-day rule real teeth. A buyer who pays after the appointed day owes the supplier compound interest, with monthly rests, at three times the RBI-notified bank rate — and three features make this different from an ordinary late fee:

  1. It is statutory, not contractual. No interest clause is needed on the invoice; the entitlement exists by operation of law and cannot be waived away by a clause in the buyer's paperwork.
  2. It compounds monthly. Interest accrues on interest every month the payment remains outstanding, not just once at the end.
  3. The multiplier is punitive by design. Three times the bank rate sits well above typical commercial borrowing costs — Parliament built in a real financial incentive to pay on time.

As of 19 July 2026, the RBI Bank Rate is 5.50% per annum (confirmed on rbi.org.in; the repo rate, a different figure, is separately 5.25%). That puts the statutory rate at 16.50% per annum, compounding monthly, for any MSE payment currently overdue. This figure moves at each bi-monthly Monetary Policy Committee review — always check the current bank rate before relying on a figure for an actual claim; a stale rate produces a stale answer.

There is also a lesser-known cross-check that works in a supplier's favour: companies must disclose in their statutory financial filings the amounts outstanding to micro and small enterprises beyond the appointed day, plus the interest accrued. A buyer who habitually delays MSME payments has to surface that fact — and the associated interest liability — to auditors, lenders, and anyone reading the accounts. Mentioning your Udyam number on invoices is what makes a buyer's finance team correctly flag you for this disclosure in the first place — see our companion piece on MSME registration benefits for the wider case for registering.

Four worked interest examples

These are educational estimates using a standard 30-day-month convention for the monthly rests — an actual MSEFC award or court decree may use calendar months and could differ slightly. The interactive calculator on this page runs the same logic on your own dates; use it, or a CA, before relying on a figure for a real claim.

Example 1 — a small, short delay. Invoice ₹1,00,000, a written 30-day agreed term, goods accepted on 1 January. The appointed day is 31 January. Payment actually lands 60 days after that (roughly 1 April) — 60 days delayed. At a 16.50% annual statutory rate compounding monthly, that works out to roughly ₹2,750–₹2,850 of interest on top of the ₹1,00,000 principal, so a total claim of about ₹1,02,800.

Example 2 — a longer delay on a larger invoice. Invoice ₹5,00,000, a written 45-day agreed term, goods accepted on 1 March. The appointed day is 15 April. Payment is made 120 days late (mid-August). Over that roughly four-month delay, compounding monthly at 16.50% produces an estimated interest figure in the region of ₹28,000–₹29,000 — a real cost the buyer has quietly taken on by treating the supplier as free short-term credit.

Example 3 — a large invoice with a part-payment. Invoice ₹25,00,000, accepted on 1 February with a 45-day term (appointed day 18 March). The buyer pays ₹10,00,000 on 1 June and the remaining ₹15,00,000 on 1 September. Interest runs on the full ₹25,00,000 from 18 March to 1 June (about 75 days), and then only on the remaining ₹15,00,000 from 1 June to 1 September (about 92 days). The two segments are calculated separately and added together — this is exactly the two-stage computation the calculator above performs when you enter a part-payment date, and it typically produces a noticeably larger figure than naively applying one flat delay period to the final balance.

Example 4 — multiple invoices with different acceptance dates. A supplier raises three invoices to the same buyer in a quarter — accepted on 5 April, 20 May, and 10 June respectively, each with a 45-day agreed term (appointed days: 20 May, 4 July, 25 July). The buyer clears all three together on 1 September. Because each invoice has its own appointed day, each carries a different number of delayed days (104, 59, and 38 days respectively) and must be computed separately, then summed — treating them as one lump delayed amount from a single date understates what is actually owed on the earlier invoices.

What the government says the Bill is expected to address

Because the official Bill text is not yet public, this section describes what has been reported about the government's intent, not confirmed statutory language. Treat every row as preliminary until the actual Bill is published.

Issue Existing MSMED Act position What's reported as the Bill's likely focus Practical impact on supplier Practical impact on buyer Effective now? Status of this claim
Delayed-payment dispute mechanism Samadhaan (legacy) → ODR portal → MSEFC conciliation/arbitration Reported intent to further "strengthen the mechanism for addressing delayed payments" Potentially faster/clearer resolution — not detailed yet Potentially faster exposure to a claim — not detailed yet No Preliminary — government messaging only
MSEFC composition and number of councils Composition largely fixed at the central/state framework level Reported flexibility for states to decide MSEFC composition, enabling more councils Possibly faster access to a local council Possibly more councils able to take up references No Preliminary — government messaging only
Arbitral award enforcement for MSEs Enforcement follows the Arbitration and Conciliation Act's general machinery Reported provision "for enforcement of arbitral awards for the MSEs" Potentially faster/cleaner enforcement of a won award Potentially reduced room to stall after losing No Preliminary — government messaging only
"Ease of doing business" / trust-based regulation N/A — general compliance framework Reported broad framing for the amendment Unclear — no specific relief named yet Possibly reduced compliance friction elsewhere in the Act No Preliminary — government messaging only
The 45-day cap itself Fixed at 45 days (Section 15) Not reported as a target of this Bill No confirmed change No confirmed change No Do not assume a change
Medium-enterprise coverage Not covered (Section 2 "supplier" definition) Not reported as a target of this Bill No confirmed change No confirmed change No Do not assume a change
Section 43B(h) (Income Tax Act) Separate statute, administered by CBDT Not part of the MSMED Act or this Bill No confirmed change No confirmed change No Different law entirely
Retrospective effect / pending cases N/A Not reported at all Unknown Unknown No Pure speculation until text is public

MSME ODR portal vs MSME Samadhaan vs MSEFC

These three names get used almost interchangeably, but they are not the same thing, and using the wrong one for a new filing can cost you time.

MSME Samadhaan MSME ODR Portal MSEFC
What it is The original online portal for delayed-payment complaints The current online dispute-resolution system for new delayed-payment cases The statutory state body that actually conciliates/arbitrates disputes
Who operates it Ministry of MSME Ministry of MSME (under the MSME RAMP programme) State governments, under the MSMED Act
New or existing claims? Mainly continues to track/service pre-existing references The route for new delayed-payment complaints today Receives references forwarded from Samadhaan (legacy) or ODR (current)
Legal status An administrative monitoring/filing system, not itself an adjudicator An administrative filing and pre-conciliation system, not itself an adjudicator The statutory adjudicating body under the Act
What happens after filing Historically, forwarded to the relevant state MSEFC Structured pre-MSEFC negotiation stage, then forwarded to MSEFC if unresolved Conciliation first; arbitration (ending in an enforceable award) if conciliation fails
Does it directly decide the dispute? No No Yes — the MSEFC is the body that actually conciliates and, if needed, arbitrates

The practical rule: if you are filing a new complaint today, use the ODR portal (odr.msme.gov.in), not Samadhaan. Confirm this on the portal itself before you file, since procedures continue to evolve.

Step-by-step: the delayed-payment recovery process

  1. Verify eligibility. Confirm your Udyam registration is current and your classification (micro/small) is correct for the relevant invoice date.
  2. Reconcile your paperwork. Match the invoice against the purchase order, delivery challan/e-way bill, and any acceptance communication.
  3. Calculate the actual deadline. Work out the appointed day from the acceptance (or deemed acceptance) date and the agreed term, capped at 45 days.
  4. Send a professional reminder. A short, factual note as the deadline approaches or just after — this alone resolves many delays.
  5. Send a formal written demand where appropriate. Reference the MSMED Act and the interest accruing; this is good practice, not a legal precondition to filing.
  6. Offer account reconciliation. Give the buyer a clear, itemised statement of what is owed, including your interest computation — disputes often hide in unreconciled ledgers.
  7. Preserve every acknowledgement. Emails, WhatsApp confirmations, signed delivery notes — anything showing the buyer received and accepted the supply.
  8. Consider TReDS or a commercial settlement. If cash flow is the immediate problem, discounting the receivable on a TReDS platform (mandatory for many large buyers with turnover above ₹250 crore since mid-2025) may get you paid faster than litigation, even at a discount — see our MSME loan guide for how TReDS and other financing routes compare.
  9. File on the current official portal. That means the MSME ODR portal for a new case, with your documents organised and your interest computation attached.
  10. Participate in conciliation. Most references that get resolved, get resolved here — engage genuinely rather than treating it as a formality.
  11. Understand the arbitration route. If conciliation fails, the MSEFC (or an institution it refers to) arbitrates, ending in a binding award.
  12. Enforce the award if needed. An MSEFC arbitration award is enforceable like any other award under the Arbitration and Conciliation Act — a buyer who still does not pay may need to face execution proceedings.

Documents and evidence checklist

  • Udyam Registration Certificate — proves your protected status and the date it took effect.
  • PAN and, where applicable, GST registration — basic identity/registration proof.
  • Purchase order, contract, or work order — fixes the agreed (or absent) payment term.
  • Tax invoice / e-invoice — the core claim document.
  • E-way bill and delivery challan — proof of movement and delivery date.
  • Goods-receipt note or service-completion confirmation — proof of acceptance.
  • Email or written acceptance/objection correspondence — establishes the acceptance date or any dispute.
  • Buyer and supplier ledger extracts — show the running account and any part-payments.
  • Bank statements — proof of non-payment or partial payment, and payment dates.
  • Part-payment proof — receipts/bank credit for any amount already received.
  • TDS certificate and relevant GST returns — cross-check the transaction was recorded on both sides.
  • Balance confirmation from the buyer, if you have one — strong corroborating evidence.
  • Demand and reminder communications — shows you tried to resolve this before escalating.
  • Quality-objection correspondence, if any — critical if the buyer disputes acceptance.
  • Your own interest computation sheet — dated, methodical, ideally reviewed by a professional.
  • Authorisation documents / board resolution, where the filer is not the proprietor personally — needed for companies and some LLPs/partnerships.

Section 43B(h): what it means for the buyer's tax return

Section 43B(h) of the Income Tax Act, inserted by the Finance Act, 2023 and effective from Assessment Year 2024-25 onward, is a separate statute from the MSMED Act — it changes when a buyer can claim a tax deduction, not whether a supplier can recover money.

What it covers. Where a buyer has purchased goods or services from a micro or small enterprise supplier and has not paid within the time limit specified under Section 15 of the MSMED Act (the same 45-day cap / agreed-period rule described above), the buyer cannot deduct that expense on the usual accrual basis. The deduction is instead allowed only in the year the payment is actually made.

The trap most buyers miss. Ordinarily, Section 43B has a relaxation: an expense is still deductible in the year it was incurred if it is paid before the tax return's due date, even if unpaid at year-end. This relaxation does not apply to clause (h). If a payment to a micro or small enterprise crosses the MSMED Act's 45-day (or 15-day default) deadline, the deduction is deferred to the year of actual payment — full stop — even if the buyer pays well before filing the return.

Who it does not cover. Section 43B(h) applies only to micro and small enterprise suppliers, not medium enterprises, and — per government clarifications on the trader carve-out — generally not to purchases from registered traders, since traders sit outside the Act's delayed-payment framework in the first place.

What it is not. Section 43B(h) does not itself recover the supplier's dues, does not create a new payment obligation beyond what Section 15 already requires, and — importantly — nothing in the verified reporting on the 2026 MSME Amendment Bill suggests this section is being changed. It sits in the Income Tax Act, administered separately from the MSMED Act amendment process.

Buyer year-end risk. A payment that crosses the MSMED deadline right before the financial year closes (31 March) is the classic trap: the expense cannot be deducted for that year even if paid a few days into the new year, and the deduction shifts to the following year's return. This is precisely why finance teams need to track MSE payment ageing separately from ordinary vendor ageing.

Supplier-side accounting and tax treatment

At a high level (and this is genuinely an area for your CA, not a DIY judgement call on a large or disputed amount):

  • Principal receivable is recognised as normal trade income/receivable in the ordinary course.
  • Statutory interest receivable raises a recognition question — whether and when to book it as income is a matter of accounting policy and the certainty of collection, and views differ.
  • GST treatment of statutory interest on a delayed commercial payment needs a specific, current professional read rather than a general assumption either way.
  • TDS questions on any interest actually paid also need a specific, current professional read.
  • Bad-debt and provisioning considerations apply if the underlying principal itself becomes doubtful, separate from the interest question.

Given how much of this turns on facts, amounts, and current departmental guidance, treat this section as a prompt to ask your CA the right questions — not as the answer itself.

Buyer compliance checklist

If you buy from micro or small suppliers, this checklist pairs with our broader guide to managing vendor payments and credit terms.

  • Capture the supplier's Udyam Registration Number during vendor onboarding, not after a dispute arises.
  • Identify micro/small status explicitly in your vendor master — do not assume "MSME" always means protected.
  • Record the acceptance date for every delivery, not just the invoice date.
  • Record the written credit period agreed, and flag anything your team wrote that exceeds 45 days as unenforceable against the supplier.
  • Monitor the 15/45-day deadlines in your payables ageing report as a distinct category from ordinary vendor terms.
  • Reconcile disputed invoices promptly and in writing — silence past 15 days locks in deemed acceptance.
  • Track year-end unpaid MSE balances specifically, because of the Section 43B(h) deduction-timing risk.
  • Coordinate with your tax auditor on any MSE payments crossing the deadline near 31 March.
  • Preserve payment evidence and acceptance correspondence — the statutory disclosure requirement and any future MSEFC reference both depend on it.
  • Never pressure a supplier to waive statutory interest as a condition of doing business — the waiver has no legal effect on Section 16 in any case.
  • Review your financial-statement disclosures on amounts due to micro and small enterprises for accuracy each reporting period.
  • Keep vendor master data (Udyam status, classification) refreshed periodically, since a supplier's category can change as it grows.

Real business scenarios

  • A rice mill buys packaging and equipment-repair services from a registered micro enterprise. The repair invoice is accepted (no objection raised) and the 45-day clock runs from the day the technician finished the work, not from the invoice date typed up two days later.
  • A manufacturer supplies components to a large corporate buyer on a "60-day" PO. The 60-day term has no effect on the supplier's statutory rights; interest still starts accruing at day 46.
  • A software services agency invoices a company for a completed sprint. "Acceptance" here is the deemed-acceptance point — if the client never formally signs off but also never objects in writing within 15 days, the clock has already started.
  • A wholesaler with Udyam registration sells goods to a retail chain. Whether the wholesaler qualifies as a "trader" excluded from these protections, or as a supplier of goods that does qualify, depends on the specific facts of the registration and activity — this is exactly the kind of boundary case worth a professional check.
  • A buyer disputes quality within the 15-day window. The clock genuinely resets to the resolution date — the supplier should get the objection resolved and documented quickly rather than letting it drag.
  • A supplier receives a 40% part-payment two months into a delay. Interest continues on the remaining 60% for the rest of the delay, and separately accrued on the full amount for the period before the part-payment — a two-segment calculation, as in Worked Example 3.
  • An invoice is raised before the supplier's Udyam registration existed. This sits in a genuinely uncertain area — do not assume the 45-day protection applies without checking the registration's effective date against the supply date.
  • A buyer pays on day 50, still within the same financial year. The MSMED Act interest liability has already arisen (payment was late), even though the Section 43B(h) year-of-deduction question may resolve differently depending on exactly when in the year this falls.
  • A buyer pays after 31 March, crossing the financial year-end. The Section 43B(h) deduction shifts to the year of actual payment — a real cash-tax cost for the buyer's finance team to plan around.
  • Multiple invoices under one purchase order, delivered on different dates. Each delivery generally has its own acceptance date and therefore its own appointed day — treat them separately for interest purposes, as in Worked Example 4.

Common mistakes

  1. Treating every "MSME" as automatically protected — medium enterprises are not covered by the 45-day rule at all.
  2. Assuming a trader gets the same delayed-payment rights as a manufacturer or service provider — this is specifically excluded by government clarification.
  3. Counting from the invoice date instead of the acceptance date — these are often different, and the Act anchors to acceptance.
  4. Assuming every invoice automatically gets 45 days — without a written agreement, the default is 15.
  5. Ignoring the 15-day appointed-day concept entirely and assuming 45 days always applies.
  6. Filing a new complaint on the old Samadhaan workflow instead of the current MSME ODR portal.
  7. Computing simple interest instead of compound interest with monthly rests — this understates the real entitlement.
  8. Using a stale RBI bank rate instead of checking the figure in force during the delay period.
  9. Filing without solid delivery/acceptance evidence — a claim with no proof of when acceptance happened is much weaker.
  10. Mixing up principal and interest in a claim or settlement negotiation, muddying what is actually owed.
  11. Ignoring part-payments in the interest calculation, instead of splitting the computation around them.
  12. Assuming Section 43B(h) itself recovers a supplier's dues — it only affects the buyer's tax deduction timing.
  13. Treating the 2026 Amendment Bill's reported provisions as if they were already law — nothing has changed until the Bill is passed and commenced.
  14. Relying on WhatsApp forwards and social media claims about the Bill instead of checking PIB, the Lok Sabha bulletin, or a published Bill text.
  15. Publishing or acting on an unverified "implementation date" for changes that have not actually happened.

Decision tree: what should you actually do?

  1. Are you a registered micro or small enterprise (Udyam), or dealing with one as a buyer? If no — these specific statutory protections do not apply to you; ordinary contract remedies govern instead.
  2. Was the registration valid at the relevant time of supply? If uncertain — get this checked before relying on the 45-day rule for an older invoice.
  3. Were the goods/services accepted, and is there a genuine written objection on record? If a live objection exists — resolve or document it before assuming a fixed appointed day.
  4. Is there a written payment agreement? If yes — your ceiling is 45 days from acceptance, whatever the paperwork says beyond that. If no — the default is 15 days.
  5. Has the applicable period (45 or 15 days) actually expired? If no — nothing is overdue yet; there is no interest claim to make.
  6. Has any part-payment been received? If yes — split your interest computation into segments around the part-payment date.
  7. Is the claim within the applicable limitation period? If you are unsure how long you have to bring a claim, get this checked — do not assume there is no time limit.
  8. Which process should you use today? A new complaint → the MSME ODR portal. A case already filed before the transition → continue tracking it via Samadhaan/ODR as directed by the portal.
  9. Is the amount, dispute, or buyer relationship complex or high-value? If yes — get a CA or lawyer to review your computation and documents before filing or settling.

Final action checklist

For suppliers — what to do when your invoice crosses the legal payment deadline:

  • Confirm your Udyam status and the correct appointed day for that specific invoice.
  • Calculate the delay and the estimated statutory interest using the interactive calculator on this page.
  • Send a factual reminder, then a formal written demand referencing the MSMED Act if needed.
  • Gather your documents (PO, invoice, delivery/acceptance proof, ledgers) into one file.
  • File on the MSME ODR portal if informal follow-up does not resolve it, and engage genuinely in conciliation.
  • Keep your working-capital buffer intact in the meantime — do not treat the receivable as cash in hand. Track every invoice's due date in an invoice tracker, and model the cash-flow impact of a slow payer using our business cash flow guide.

For buyers — what to do before an MSE invoice crosses the payment deadline:

  • Capture Udyam status and classification at vendor onboarding, not after a dispute starts.
  • Record the acceptance date accurately, and resolve any quality objection in writing within 15 days.
  • Track the 45/15-day deadline in payables ageing as its own category, separate from ordinary vendor terms.
  • Never let an MSE balance cross 31 March unpaid without flagging it to your tax team for the Section 43B(h) impact.
  • Pay on time — the statutory interest, the tax-deduction risk, and the mandatory disclosure all make a delayed MSE payment more expensive than it looks.

Editorial update note — what to change on this page, and when:

  • Bill introduced: add the Bill number, exact introduction date, and House; move the status box from "listed" to "introduced"; keep the headline unless the Scenario in this article's brief changes.
  • Bill text published: replace the "What the government says the Bill is expected to address" table with a real existing-law-vs-enacted-clause comparison, citing exact sections; switch the headline to the "text available" scenario.
  • Standing Committee referral: note the referral and expected report timeline in the status box.
  • One House passes it: update the headline to the "passed by [House]" scenario; update the status box's "current stage."
  • Parliament passes it: update the headline to the "passed" scenario; add passage dates for both Houses.
  • Presidential assent: record the assent date; note that the Act is amended but not yet commenced unless the amendment says otherwise.
  • Gazette notification / commencement date confirmed: switch the headline to the "new rules 2026" / effective scenario; update every "existing law" table to reflect the new legal position; rewrite the FAQ answers that currently say "not yet."
  • Rules or ODR/MSEFC procedures are revised: update the ODR-vs-Samadhaan-vs-MSEFC table and the step-by-step process accordingly.
  • RBI changes the bank rate: update the calculator's default rate, the worked examples, and the "as of [date]" rate references throughout.

Frequently Asked Questions

Sources and references

Rules, rates, and thresholds in India change over time. Always confirm the current position with the official source above before acting on it.